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6015. P is not entitled to relief under I.R.C. secs.
6015(b), (c), and (f) because she did not file a joint
return.
Ranie M. Raymond, pro se.
A. Gary Begun, for respondent.
OPINION
VASQUEZ, Judge: This case is before the Court on
respondent’s motion for partial summary judgment under Rule 121.1
Background
At the time of the filing of the petition, petitioner
resided in Livonia, Michigan. On her 1991 Federal income tax
return, petitioner’s filing status was listed as “Married filing
separate return”. At the time of the filing of the tax return,
no payment was made on the amount reported as due on the tax
return. Respondent applied petitioner’s tax refunds from 1995
and 1998 in partial satisfaction of the amount due for 1991.
On July 11, 2000, respondent sent petitioner a Final Notice:
Notice of Intent to Levy and Notice of Your Right to a Hearing.2
On January 9, 2001, respondent sent petitioner a Notice of
Determination Concerning Collection Action(s) Under Section 6320
1 Unless otherwise indicated, all Rule references are to
the Tax Court Rules of Practice and Procedure, and all section
references are to the Internal Revenue Code in effect at all
relevant times.
2 The notice listed that petitioner owed $7,097.82 in
unpaid taxes for 1991 and $8,211.05 in penalties and interest for
that year.
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